Right to counsel
While a state may have many statutes, court decisions, or court rules governing appointment of counsel for a particular subject area, a "Key Development" is a statute/decision/rule that prevails over the others (example: a state high court decision finding a categorical right to counsel in guardianships cases takes precedence over a statute saying appointment in guardianship cases is discretionary).
Litigation, Incarceration for Fees/Fines (incomplete)
Six years prior to the codification of Kentucky’s statutory right to counsel, the Kentucky Court of Appeals (at the time, the Kentucky Court of Appeals was the highest court in the state), in Wright v. Crawford, 401 S.W.2d 47 (Ky. App. 1966), found a non-statutory right to counsel in cases where a civil litigant faces the possibility of incarceration. 401 S.W.2d at 49 (finding that indigent defendant subjected to incarceration for failure to pay civil judgment was entitled to counsel on same terms as in criminal case where statute permitted imprisonment). Although the Wright court said it was not going to “enter upon full consideration or discussion of whether ‘due process' demands appointment of counsel for an indigent litigant in a civil case,” the court nonetheless reasoned that “the litigant’s liberty is as surely impaired by” a civil judgment that imposes a jail sentence as by a criminal one. Id. (internal citation omitted). The case would likely apply to all contempt proceedings that result in incarceration.
If "yes", the established right to counsel or discretionary appointment of counsel is limited in some way, including any of: the only authority is a lower/intermediate court decision or a city council, not a high court or state legislature; there has been a subsequent case that has cast doubt; a statute is ambiguous; or the right or discretionary appointment is not for all types of individuals or proceedings within that category.
Appointment of Counsel: categorical Qualified: yes